Case Digest (G.R. No. 161318) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Julie Nabus, Michelle Nabus and Betty Tolero v. Joaquin Pacson and Julia Pacson (620 Phil. 344, decided November 25, 2009 under the 1987 Constitution), the Spouses Bate and Julie Nabus owned 1,665 square meters of land in Pico, La Trinidad, Benguet, registered under TCT No. 9697 but mortgaged to the Philippine National Bank (PNB) for ₱30,000. On February 19, 1977, they executed a Deed of Conditional Sale covering 1,000 square meters to the Pacsons for ₱170,000, stipulating (1) P13,000 to be paid directly to PNB; (2) full liquidation of the PNB mortgage in monthly installments of at least ₱3,000; and (3) further payments of at least ₱2,000 monthly until the full ₱170,000 was paid. Title was to pass only “as soon as the full consideration … has been paid.” Respondents paid PNB ₱12,038.86 in February 1977 and ₱20,744.30 in July 1978, then made 364 receipts of varied small payments totaling ₱112,455.16 from March 1977 to January 1984, leaving a balance of ₱57,544.84. In March 198 Case Digest (G.R. No. 161318) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Original Ownership and Conditional Sale
- Spouses Bate and Julie Nabus owned 1,665 sqm land in Pico, La Trinidad, Benguet (TCT No. 9697), mortgaged to PNB for ₱30,000.
- On February 19, 1977, they executed a “Deed of Conditional Sale” of 1,000 sqm to spouses Joaquin and Julia Pacson for ₱170,000, payable as follows:
- ₱13,000 on or before February 21, 1977, direct to PNB;
- Balance of mortgage (~₱17,500) at ≥₱3,000/month to PNB;
- After full mortgage payment, ≥₱2,000/month to Nabus until total ₱170,000 paid.
- Vendees obligated to shoulder segregation survey costs. Vendor warranted refund if title lost in pending litigation.
- Payment, Possession, and Title Changes
- Pacsons paid PNB ₱12,038.86 (Feb 22, 1977) and ₱20,744.30 (Jul 17, 1978). They ousted occupants, built a repair shop, and took possession.
- Bate Nabus died December 24, 1977; Julie and minor Michelle executed extrajudicial settlement (Aug 17, 1978), leading to TCT No. T-17718 in their names (Feb 17, 1984).
- From March 1977 to January 1984, Pacsons made 364 payments totaling ₱112,455.16, leaving balance ₱57,544.84.
- Subsequent Sale to Third Party
- In March 1984, Julie Nabus executed an absolute sale of entire 1,665 sqm to Betty Tolero for ₱200,000; TCT Nos. T-18650 to T-18653 issued (Mar 16, 1984).
- Tolero padlocked Pacsons’ shop gate; Pacsons filed a complaint for annulment of deeds, damages, and preliminary injunction (RITC Civil Case No. 84-CV-0079).
- Lower Courts’ Decisions
- RTC (Sept 30, 1993) found:
- Deed of Conditional Sale was a sale, not lease;
- Tolero had actual knowledge of Pacsons’ rights → not in good faith.
- Ordered Tolero to execute deed of absolute sale to Pacsons upon payment of ₱57,544.84; awarded moral (₱50,000), exemplary (₱20,000) damages, and attorney’s fees (₱10,000).
- CA (Nov 28, 2003) affirmed with deletion of attorney’s fees award.
- Supreme Court Review
- Parties’ contentions centered on:
- Conversion of conditional sale into lease;
- Nature of the contract (absolute sale vs. contract to sell);
- Good faith of subsequent purchaser;
- Entitlement to specific performance and damages.
Issues:
- Whether the Deed of Conditional Sale was converted into a contract of lease.
- Whether the contract between the Nabuses and the Pacsons is a contract of sale or merely a contract to sell (conditional sale).
- Whether, given the nature of the contract, the subsequent absolute sale to Betty Tolero and issuance of new titles are valid.
- What remedies, if any, are available to the Pacsons for their payments under the conditional sale.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)